Decision

Advice Letter: Robert Halfon, Contractor Trainer, Dods Training

Published 3 October 2024

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Robert Halfon, former Minister of State for Skills, Apprenticeships and Higher Education for the Department for Education. Paid appointment with Dods Training.

You approached the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointments Rules for Former Ministers (the Rules) seeking advice on taking up a paid role as a Contractor Trainer with Dods Training.

The purpose of the Rules is to protect the integrity of the government. The Committee has considered the risks associated with the actions and decisions made during your time in office, alongside the information and influence you may offer Dods Training as a former minister. The material information taken into consideration by the Committee is set out in the annex.

The Committee’s advice is not an endorsement of the appointment - it imposes a number of conditions to mitigate the potential risks to the government associated with the appointment under the Rules. 

The Ministerial Code sets out that ministers must abide by the Committee’s advice. It is an applicant’s personal responsibility to manage the propriety of any appointment. Former ministers of the Crown, and Members of Parliament, are expected to uphold the highest standards of propriety and act in accordance with the 7 Principles of Public Life.

2. The Committee’s consideration of the risks presented

The Department for Education (DfE) confirmed that it does not have a direct relationship with Dods Training. It noted that the company is a subcontractor for Civil Service Learning – which is managed by the Cabinet Office. DfE confirmed you did not meet with, nor were you involved in policy or commercial decisions specific to Dods Training. Therefore, the Committee^{[footnote 1]} considered the risk that you were offered this role as a reward for decisions made or actions taken in office was low. 

The Committee noted there are inherent risks regarding your general access to information and influence within government as a result of your time as a minister. The risks are limited given there is no direct overlap between your government service and this proposed role. It is also relevant that you have been out of government for more than four months, providing a gap between your access to information and your taking up this role. 

As a former minister, there are inherent risks associated with your contacts and influence within government. The Committee noted your role does not involve contact with government.

3. The Committee’s advice

The Committee did not consider this appointment to raise any particular propriety concerns under the government’s Rules. There are inherent risks associated with your access to sensitive information and contacts which the standard conditions below appropriately mitigate. In particular, they prevent  you from drawing on your privileged information and using your contacts and influence within government to the unfair advantage of Dods Training.

In accordance with the government’s Business Appointment Rules, the Committee advises this role with Dods Training be subject to the following conditions: 

• you should not draw on (disclose or use for the benefit of yourself or the persons or organisations to which this advice refers) any privileged information available to you from your time in ministerial office;

• for two years from your last day in ministerial office, you should not become personally involved in lobbying the UK government or its arm’s length bodies on behalf of Dods Training (including parent companies, subsidiaries, partners and clients); nor should you make use, directly or indirectly, of your contacts in the government and/or ministerial office to influence policy, secure business/funding or otherwise unfairly advantage Dods Training (including parent companies, subsidiaries, partners and clients); and

• for two years from your last day in ministerial office, you should not undertake any work with Dods Training (including parent companies, subsidiaries, partners and clients) that involves providing advice on the terms of, or with regard to the subject matter of a bid with, or contract relating directly to the work of, the UK government or its arm’s length bodies.

The advice and the conditions under the government’s Business Appointment Rules relate to your previous role in government only; there are separate rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists, the Parliamentary Commissioner for Standards and the Registrar of Lords’ Interests.^{[footnote 2]} It is an applicant’s personal responsibility to understand any other rules and regulations they may be subject to in parallel with this Committee’s advice.

By ‘privileged information’ we mean official information to which a minister or Crown servant has had access as a consequence of his or her office or employment and which has not been made publicly available. Applicants are also reminded that they may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Civil Service Code or otherwise.

The Business Appointment Rules explain that the restriction on lobbying means that the former Crown servant/Minister “should not engage in communication with government (Ministers, civil servants, including special advisers, and other relevant officials/public office holders) – wherever it takes place - with a view to influencing a government decision, policy or contract award/grant in relation to their own interests or the interests of the organisation by which they are employed, or to whom they are contracted or with which they hold office.”

You must inform us as soon as you take up employment with this organisation, or if it is announced that you will do so. Please also inform us if you propose to extend or otherwise change the nature of your role as, depending on the circumstances, it may be necessary for you to make a fresh application.

Once the appointment has been publicly announced or taken up, we will publish this letter on the Committee’s website, and where appropriate, refer to it in the relevant annual report.

4. Annex- Material information

4.1 The role 

According to its website, Dods Training is a private training provider offering training on the workings of government and parliament, including policy making, governance, leadership and management, communication skills and media handling.

You stated that as a paid, part-time, ad hoc Contractor Trainer, your role will be to develop and deliver courses on how to work with ministers, prepare for select committees and other sessions focused on civil service and parliamentary engagement. 

You confirmed your role will not involve contact with government. 

4.2 Dealings in office

You advised the Committee that; you did not meet with, nor were you involved in decisions specific to Dods Training; and that you did not have access to sensitive information specific to Dods Training. 

4.3 Departmental Assessment

DfE confirmed the details you provided and stated: 

• Dods Training is a subcontractor for the Civil Service Learning contracts, which are held under the Cabinet Office - DfE stated that it does not hold a direct relationship with the company, under its Learning & Development framework; 
• you were not involved in decisions specific to Dods Training;
• you had access to privileged information, but did not note anything specific to Dods Training that was likely to provide an unfair advantage;
• you have general knowledge and experience of working in government which may be helpful to Dods in refining their training products and approaches, but DfE’s assumption is that this general knowledge and experience does not fall within the scope of concerns under the Rules. 

DfE did not have concerns with the appointment and recommended the standard conditions.

1. This application for advice was considered by Isabel Doverty; Hedley Finn OBE; Sarah de Gay; Dawid Konotey-Ahulu CBE DL; The Rt Hon Lord Eric Pickles; Michael Prescott; and Mike Weir. Andrew Cumpsty was unavailable. ↩

2. All Peers and Members of Parliament are prevented from paid lobbying under the the House of Commons Code of Conduct and the Code of Conduct for Members of the House of Lords. Advice on your obligations under the Code can be sought from the Parliamentary Commissioners for Standards, in the case of MPs, or the Registrar of Lords’ Interests, in the case of peers ↩